EXHIBIT 99


                             BRIGHTON COMMERCE BANK

                    PROXY FOR SPECIAL MEETING OF SHAREHOLDERS

                         To Be Held On January 26, 2000

               THIS PROXY IS SOLICITED BY THE BOARD OF DIRECTORS.

     The undersigned  shareholder of BRIGHTON COMMERCE BANK hereby appoints GARY
NICKERSON and ROBERT C. CARR, or either of them, to represent the undersigned at
the special meeting of the shareholders of BRIGHTON  COMMERCE BANK to be held on
JANUARY 26, 2000, at 9:00 a.m.  (local time),  at Brighton  Commerce Bank,  8700
North Second  Street,  Brighton,  Michigan  48116,  and at any  adjournments  or
postponements thereof, and to vote the number of shares the undersigned would be
entitled to vote if  personally  present at the  meeting on the  matters  listed
below.

     When properly executed,  this proxy will be voted in the manner directed by
the undersigned  shareholder and in the discretion of the proxy holder as to any
other matter that may come before the special meeting of shareholders and at any
adjournment or postponement  thereof.  If no direction is given, this proxy will
be voted "FOR" the proposal to approve and adopt the Plan of Share  Exchange and
in the  discretion  of the proxy holder as to any other matter that may properly
come before the meeting or any adjournments or postponements thereof.

     WHETHER OR NOT YOU EXPECT TO ATTEND THE MEETING, YOU ARE URGED TO COMPLETE,
DATE, AND PROMPTLY  RETURN THIS PROXY IN THE ENCLOSED  POSTAGE-PAID  ENVELOPE SO
THAT YOUR SHARES MAY BE REPRESENTED AT THE MEETING.

     THE BOARD OF DIRECTORS  RECOMMENDS A VOTE "FOR" THE APPROVAL OF THE PLAN OF
SHARE EXCHANGE.

     1.  Proposal to approve and adopt the Plan of Share  Exchange,  dated as of
January 31, 2000, between and among CAPITOL BANCORP LTD. and the shareholders of
BRIGHTON  COMMERCE  BANK to  exchange  the  shares of common  stock of  BRIGHTON
COMMERCE BANK not now held by CAPITOL BANCORP LTD. for shares of common stock of
CAPITOL BANCORP LTD. according to the terms of the Plan of Share Exchange. After
the share exchange,  BRIGHTON COMMERCE BANK will be a wholly owned subsidiary of
CAPITOL BANCORP LTD.


                [ ] FOR         [ ] AGAINST         [ ] ABSTAIN

[SIGNATURES ON REVERSE]

Dated: JANUARY ________, 2000

                                           ------------------------------------
                                             Number of Shares of Common Stock

                                           ------------------------------------
                                           Signature (and title if applicable)

                                           ------------------------------------
                                               Signature (if held jointly)

                                           Please  sign your name  exactly as it
                                           appears  on your  stock  certificate.
                                           When   shares   are   held  by  joint
                                           tenants,   both  should  sign.   When
                                           signing   as   attorney,    executor,
                                           administrator,  trustee or  guardian,
                                           please give full title as such.  If a
                                           corporation,   please  sign  in  full
                                           corporate  name by the  President  or
                                           other   authorized   officer.   If  a
                                           partnership,     please    sign    in
                                           partnership    name   by   authorized
                                           person.